Fisheries ministers poised to breach EU law and exacerbate Baltic ecosystem crisis, NGOs warn

CCB • October 19, 2023

On 23rd October, EU fisheries ministers will set Baltic Sea fishing limits for next year. Their decisions will likely breach EU law and worsen the dire state of the Baltic Sea, as Member States have made clear that they don't support cuts to Baltic fishing opportunities in order to bring them in line with legal obligations. NGOs are urging fisheries ministers to suspend the fishing of severely depleted stocks, as foreseen by EU law in these circumstances.

To prevent the collapse of fish populations, EU multiannual management plans require that fishing opportunities are set so that fish populations are at the very least kept above a minimum level (1). This year, due to persistent overfishing, scientific data shows that two herring stocks in the central and northern Baltic are now at or below this clear red line. Any targeted fishery on these herring stocks would be in breach of EU law. 


Detailed rules for how to set fishing quotas and agree on emergency measures, including the option of complete fisheries closures, are set out under EU multi-annual management plans, in line with the objectives of the EU’s Common Fisheries Policy (CFP). Following the rules of the Baltic multi-annual management plan and the status of these herring populations, the European Commission has proposed to close the targeted fishery for herring in these two areas. 


To date, however, Baltic Member States have argued that the Commission proposal is going too far, and have questioned the interpretation of the regulations in place. In doing so, the Member States are disregarding the very clear rules and the obvious fact that both these herring populations are below the agreed minimum levels.


Nils Höglund, Senior policy officer at CCB, said: “By aiming to evade the rules in the Baltic management plan and the CFP in relation to avoiding fish stock collapse, and pushing to keep what is largely a fishmeal fishery open, the Council is breaching both EU fisheries and environmental legislation, such as the Marine Strategy Framework Directive (MSFD). The possibility to reach good environmental status is likely made near impossible by the Agrifish Council. This approach must be deemed doubly illegal”. 


Sara Söderström, Policy officer at the Fisheries Secretariat, said: “The health of the Baltic Sea ecosystem depends on forage fish such as herring and sprat, which feed other fish, mammals and seabirds. It is clear that when we remove large amounts of biomass it disrupts the food web and negatively affects the age and size distribution of herring, defying the targets in both the CFP and the MSFD. If we are to achieve an ecosystem-based approach to fisheries management, a much more precautionary approach must be applied.” 


Bruno Nicostrate, Senior Policy Officer at Seas At Risk, said: “If EU Fisheries Ministers fail to comply with EU law not only will they contribute to the disappearance of Baltic herring populations, they will also pave the way for the decimation of other fish species. EU Member States must respect the very laws they have co-designed and signed up to and prevent this impending ecocide by putting a stop to fishing of endangered fish populations." 


Javier Lopez, Campaign Director of sustainable fisheries at Oceana in Europe, said: “It is inconceivable to see EU Member States attempting to set catch limits for Baltic stocks that ignore the very rules they have created themselves. Several populations of iconic species such as eastern Baltic cod and central Baltic herring are in a critical state and targeted fishing of them must stop. Ministers cannot cherry-pick the law for political expediency, but must rather apply it comprehensively for the sake of the health and sustainability of fisheries.”


ClientEarth marine wildlife and habitats lawyer Arthur Meeus said: “According to EU law, overfishing should have ended by 2020 for all stocks. Instead, overfishing of already depleted stocks continues not only in the Baltic, but throughout the EU’s seas. It is high time for a clear court decision to put an end to this systemic issue. Multiple court cases are already underway to get this much needed clarity and we are eagerly awaiting the first judgment of the Court of Justice of the European Union. This official ruling from the EU’s top Court will be crucial to finally give EU fisheries rules the teeth needed to ensure Member States can only manage fisheries in line with science and the law going forward.”



BACKGROUND 


Herring and sprat play key roles in the Baltic ecosystem as they are a food source for predators, like cod and salmon and also regulate plankton. Today, this valuable resource is mainly used for fish meal, rather than human consumption.

According to the latest scientific data, herring in the central Baltic Sea is in a critical condition with a disheartening outlook. The Bothnian herring is also in a critical state and experts note that even with a complete fishing closure, the stock will not recover in the short term. Article 4(6) of the Baltic multiannual management plan explicitly requires that “Fishing opportunities shall in any event be fixed in such a way as to ensure that there is less than a 5 % probability of the spawning stock biomass falling below Blim”. The herring stocks in question are already below this biological reference point Blim, below which reproduction is impaired and the risk of stock collapse is very high. Setting fishing limits at levels associated with a higher than 5% risk of the stocks remaining below this level, as seems to be the intention of Baltic Member States, will be in breach of the law.


In 2020, Friends of the Irish Environment and ClientEarth challenged the EU Council’s decision to set limits for several Northeast Atlantic fish stocks above sustainable levels before an Irish Court.


In a legal first, the Irish judge asked the Court of Justice of the EU (CJEU) to judge on the validity of this European regulation setting fishing limits in the Northeast Atlantic. Following a hearing held in March 2023 in front of the CJEU, Advocate General Ćapeta delivered an Opinion in June 2023 claiming that unsustainable fishing limits in the Northeast Atlantic were illegal and recommended that governments set all fishing limits at sustainable levels from now on. The environmental groups are now waiting for the final ruling from the CJEU.


ClientEarth is also expecting hearings this year for two other cases launched in 2022 against the EU Council for the setting of unsustainable fishing limits for EU-only stocks and stocks shared between the EU and the UK.


NOTES: 


(1) Article 4.6 of the multiannual plan for the stocks of cod, herring, and sprat in the Baltic Sea states that: “Fishing opportunities shall in any event be fixed in such a way as to ensure that there is less than a 5 % probability of the spawning stock biomass falling below the limit spawning stock biomass reference point (Blim) set out in particular in Annex II, column B.” https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02016R1139-20201201 



ENDS 


CONTACTS 

Call for Consultant / Expert : CCB Shadow Implementation Plan on the HELCOM Regional Action Plan for benthic habitat restoration

By CCB • June 2, 2026
About CCB Coalition Clean Baltic – CCB is a politically independent network, uniting 28 environmental non-profit organizations, as well as partners and experts from 11 countries surrounding the Baltic Sea. The main goal of CCB is to promote the protection and improvement of the environment and natural resources of the Baltic Sea region by encouraging new and constructive approaches and engaging people to become part of the solution instead of part of the problem. CCB Secretariat is based in Uppsala, Sweden. Background The HELCOM Baltic Sea Action Plan (BSAP) from 2021 includes a commitment to develop a regional action plan for habitat and biotope restoration by 2026. This plan is expected to: Define qualitative and quantitative restoration targets Establish a prioritized list of restoration actions Provide an implementation toolbox of best practices and methods The scope of the HELCOM action plan focuses exclusively on benthic habitats and biotopes , with particular emphasis on active restoration measures . Adoption of the plan is foreseen at the HELCOM Ministerial Meeting in November 2026. Coalition Clean Baltic (CCB) recognizes the importance of the HELCOM process but also the need to strengthen ambition, improve implementation guidance, consider a source-to-sea approach, and ensure long term ecological effectiveness . Therefore, a CCB Shadow Restoration Implementation Plan will complement and critically assess the HELCOM Restoration Action Plan. The purpose of the CCB Shadow Restoration Implementation Plan is to: Provide a science-based and practice-oriented complement to the HELCOM Restoration Action Plan Identify gaps, weaknesses, and missing elements in the HELCOM Restoration Action Plan Propose concrete, implementable actions, under a source-to-sea approach, to ensure effective restoration outcomes Strengthen alignment with the BSAP objectives and broader regional and EU policies Your Role You will compile the CCB Shadow Restoration Implementation Plan with aims to: 1. Assess the proposed HELCOM restoration measures , particularly their expected ecological impact by Reviewing proposed HELCOM actions for benthic habitats Evaluating whether actions are sufficient to achieve good environmental status Identifing missing measures, insufficient ambition, or unclear guidance 2. Define recommendations on how restoration should be implemented in practice including Required scale, intensity, and geographic coverage of actions Feasibility and effectiveness of active restoration methods 3. Propose additional actions and priorities , especially where the scope of the HELCOM action plan is insufficient, such as Integration of a source-to-sea approach for better ecological coherence Passive restoration measures Including actions on riverine systems (barrier removal, flow restoration) and coastal ecosystems (dunes, wetlands, lagoons) Incorporating important fish habitats and spawning/nursery areas, as well as ecosystem connectivity 4. Align HELCOM restoration efforts with other relevant policy frameworks , including the Baltic Sea Action Plan, Marine Action Plan, EU Biodiversity Strategy, Nature Restoration Regulation, Marine Strategy Framework Directive, Maritime Spatial Planning Directive, Water Framework Directive and Common Fisheries Policy. This is a Joint efforts with WWF Baltic Sea Programme The organisations, CCB and WWF Baltic Sea Program, will produce two separate documents with separate logos and will be presented at a joint side-event at the HELCOM Ministerial Meeting in November 2026. Actions for the Consultant/Expert & products to deliver The final document of the shadow restoration implementation plan Conduct interviews with all WA Leaders and MOs of CCB working on restoration to gather concrete input Share at the end all notes of the research and transcripts of interviews with MOs Bi-weekly call of consultant + CCB to check-in on progress, problems and next steps Publications/Sources CCB Restoration Guidelines https://irp.cdn-website.com/53007095/files/uploaded/CCB+Restoration+Guidelines_Update+October+2025.pdf CCB BSAP Shadow Plan: https://www.ccb.se/publication/Shadow%20Plan Profile A college degree, preferably in marine science, political science, environmental studies, social sciences, or a comparable field Experience in political campaigning, strategic communication, or advocacy, ideally in environmental, climate, nature, or marine conservation, preferably with an NGO Knowledge about relevant political settings and frameworks in the Baltic Sea (HELCOM, BSAP, MSFD, NRRL, ...) Experience in collaborating with coalitions, initiatives and civil society actors Initiative, independence and reliability working fully remotely Excellent written and spoken English are required Contract Terms Contract Type: can be structured as a consulting contract or a fixed-term employment (for candidates based in Sweden). We are open to discuss what works best depending on your situation. Time: From 15 June until 15 Oct 2026, at 50-75% work pace. Location: Remote position. Application Process: Should you be interested in applying for this position please send your CV (max. 2 pages) together with a personal letter (max. 1 page) before 9 June 2026 to: secretariat@ccb.se *** Being an international organization, CCB’s work is carried out in English. Applications submitted in any other language will not be considered. Incomplete applications (e.g. lacking either CV or personal letter) will be also not considered. We will be reviewing applications as they come in and encourage early applications. Only shortlisted candidates will be contacted. *** For inquiries , contact CCB Biodiversity Officer: andrea.cervantes@ccb.se Equal Opportunities CCB is an equal opportunity employer. In the application and hiring process, CCB will not discriminate against any individual based on race, colour, sex, language, religion, national or social origin, property, disability, age, family status, sexual orientation and gender identity, economic and social situation.

Fishing & NGOs:Sustainable herring fishing in the Gulf of Bothnia is strengthened through better knowledge, long-term and ecosystem-based fisheries management, and protection of herring spawning areas

By CCB • May 28, 2026
28 May 2026 - Baltic Sea herring stocks and the herring fisheries have in recent years become a central point of contention in Baltic Sea fisheries policy. Member States' approaches to the International Council for the Exploration of the Sea (ICES) recommendations for herring quotas have varied, and the public debate around herring is polarised. At the same time, dialogue between groups of fishers and other stakeholders in different countries has been limited, and not all actors have had a clear picture of each other's perspectives and needs. Within the framework of the Fisheries for the Future project, funded by Ålandsbanken’s Baltic Sea Project, Finnish and Swedish fishers, environmental organisations and researchers gathered last autumn to discuss the status of herring stocks and fishing in the Baltic Sea. Participants gained a better understanding of differences between countries and areas regarding stock status, fisheries management and research. The organisations that took part in the workshop all agree on the need for joint dialogue and wish for the cooperation to continue. “ The project combines research and practical understanding of the herring situation in the Baltic Sea. That makes the initiative particularly important, as the lessons learned can contribute to better decisions and more accurate measures going forward ," notes Crista Hietala, Head of Marketing and Communications at Ålandsbanken and the Baltic Sea Project. During the workshop, a shared understanding emerged of the complexity of the issue, where fishing is one factor but not the only cause of the state of the stocks. The need for a holistic approach was emphasised, in which environmental changes and factors affecting fisheries regulation are considered alongside fishing itself. " Herring stocks are affected by a range of interacting factors – from water quality and salinity to changes in food webs and climate change. At the same time, knowledge about how these factors interact remains limited, which contributes to increased uncertainty in management ," says Aimi Hamberg, Marine Policy Officer at Coalition Clean Baltic. More stable quotas increase predictability The predictability and economic sustainability of fishing can be improved by reducing annual variations in fishing quotas. Multi-annual and more stable quotas would facilitate the planning of fishing operations and better secure the herring's central role in the Baltic Sea ecosystem. The fishing and environmental organisations that participated in the workshop propose that EU member states ask the International Council for the Exploration of the Sea (ICES) to investigate how the quota system can be developed in a more stable and long-term direction, while at the same time ensuring the recovery of sustainable herring stocks. More knowledge about herring spawning areas Workshop participants emphasise that a significantly better knowledge base is needed about herring spawning and nursery areas than what we have today. Updated information on the most important reproduction areas for herring is central to marine spatial planning, for example when siting offshore wind power and other uses of sea areas. Towards ecosystem-based stock assessments During the workshop, it was recommended that herring stock assessments should be based on an ecosystem perspective. ” We believe that stock assessments and advice on fishing quotas need to take greater account of changes in central ecosystem factors, such as predation by seals and cormorants. It is important to expand data collection in order to achieve this ," say representatives of Vi Svenska Fiskare (We Swedish Fishers). As a first step, workshop participants recommend that Finland and Sweden initiate a joint regional project in the Gulf of Bothnia, which can later be extended to other parts of the Baltic Sea. Management areas should be reviewed – dialogue on protected areas needs to continue The workshop highlighted the need to review the division of management areas in the Baltic Sea. Participants propose that the Bothnian Sea and the Bothnian Bay be separated as distinct regulatory areas. This is motivated by genetic differences between the stocks and the fish's migration patterns. In addition, participants consider it important to continue the dialogue on possible protected areas in the Bothnian Sea. Such areas could be introduced as time-limited pilot trials, whose effects are evaluated scientifically. The dialogue on protected areas in the Bothnian Sea has continued between the organisations at a meeting held in February. *** Related documents Read the press release in Swedish and in Finnish . Main outcomes of the workshop in Swedish and Finnish. *** Further information The Fisheries for the Future workshop was a collaborative project between the environmental organisation Coalition Clean Baltic (CCB) and WWF Finland, with funding from Ålandsbanken’s Baltic Sea Project. Among the represented fishing organisations were Suomen Ammattikalastajaliitto/Finlands Yrkesfiskarförbund (Finnish Professional Fishers' Association), Österbottens Fiskarförbund (Ostrobothnia Fishers' Association), Vi Svenska Fiskare (We Swedish Fishers), Kustfiskarna Bottenhavet (Bothnian Sea Coastal Fishers), Ålands fiskare (Åland Fishers) and Sportfiskarna (the Swedish Anglers' Association). Fisheries management was represented by the Government of Åland and the County Administrative Board of Stockholm. In addition, experts from the Natural Resources Institute Finland, the University of Turku and the Swedish University of Agricultural Sciences participated.